Georgetown Professor Adam Levitin stops by Clark Hill’s Credit Eco to Go to provide his objective perspective on the CFPB's Final Debt Collection Rule. Overall Adam supports a having clear rules of the road, regardless of whether you agree with the rule itself. He agrees that having a rule that provides guidance for debt collectors to navigate the electronic ecosystem is very important and was glad to see that a model validation was finalized but believes it will be tweaked over time. Adam does have concerns about the frequency limits with regard to attempts to communicate by telephone and worries that repeated and unwanted calls find their way into harassment. Finally, Adam was very surprised that the CFPB did not move forward with a final rule on time-barred debt but suspects the issue may still be addressed down the road, maybe in a UDAAP rulemaking. The conversation about debt collection and the debt collection rule may be headed into extra innings.
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Funk Game Loop by Kevin MacLeod